Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of burglary, entered following a jury trial, holding that Defendant was not entitled to relief on his argument that he should be granted an acquittal.Defendant was indicted for various offenses, including burglary. During the jury trial, after the State rested, Defendant moved for a judgment of acquittal on the grounds that the State had not proven that he was not licensed or privileged to be in the house at issue because he was legally present on the premises as a tenant. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence in the record from which the jury could find that Defendant knew that he lacked the right to possess or occupy the premises the night of the offense; and (2) therefore, Defendant was not entitled to an acquittal. View "State v. Every" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault but vacated his sentence of eight years' imprisonment to be followed by eight years of supervised release, holding that there was no error in Defendant's conviction but that the sentencing analysis used by the trial court resulted in obvious error that required correction.On appeal, Defendant argued that the trial court committed obvious error in its treatment of a note from the jurors during jury deliberations and because of prosecutorial error. The Supreme Judicial Court remanded the case for resentencing, holding (1) Defendant waived any objection to the court's response to the note; (2) there was no prosecutorial error or impropriety; and (3) the lower court had the authority to impose what was a lawful amended sentence, but the sentencing analysis employed by the court required that this Court vacate the sentence and remand for a de novo sentencing hearing. View "State v. Cummings" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for aggravated assault, robbery, domestic violence assault, domestic violence criminal threatening, and theft by unauthorized taking or transfer but reversed his sentence, holding that the trial court erred by failing to merge duplicative counts.The Supreme Judicial Court remanded this case for resentencing, holding (1) the trial court did not err in failing to give a specific unanimity instruction in addition to the given general unanimity instruction; (2) the trial court erred in failing to merge the duplicative counts of theft by unauthorized taking or transfer and robbery, resulting in a double-jeopardy violation; and (3) the trial court's reliance on Defendant's decision to seek a trial as an aggravating factor in his sentence was unconstitutional. View "State v. Chase" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for three counts of intentional or knowing murder, among other crimes, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant challenged the decision of the trial court to admit a statement that he made to police in which he identified the number and names of his victims and argued that the trial court committed obvious error by instructing the jury on the thirty-party provocation exception to the use of deadly force. The Supreme Judicial Court affirmed, holding (1) any error in admitting Defendant's challenged statement was harmless beyond any reasonable doubt; and (2) the trial court did not commit obvious error by reciting a portion of the self-defense statute that was not generated by the evidence. View "State v. Bonfanti" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of gross sexual assault and two counts of unlawful sexual contact, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the district court did not abuse its discretion in denying Defendant's motion for a continuance; (2) there was no constitutional error in the trial court's ruling requiring that participants in Defendant's trial be masked; (3) there was no prosecutorial error in either the State's opening or closing argument or in the State's rebuttal argument; and (4) Defendant's claims of evidentiary error were unavailing. View "State v. Hunt" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder and his thirty-five-year sentence, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of murder and robbery of the same victim. On remand, the trial court sentenced Defendant to thirty-five years for the murder conviction and twenty tears for the robbery conviction, to be served concurrently. The Supreme Judicial Court affirmed, holding (1) the lower court did not violate Defendant's constitutional rights to a sentence proportional to the offense in imposing the sentence; and (2) the lower court did not obviously err in failing to provide the jury a self-defense instruction under Me. Rev. Stat. 108(2)(A)(2). View "State v. Asante" on Justia Law

The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

The Supreme Judicial Court vacated the series of consecutive sentences imposed by the trial court upon Appellant's guilty pleas to ten counts of aggravated attempted murder and other crimes, holding that the trial court did not make the factual findings required for the imposition of consecutive sentences.Appellant pleaded guilty to ten counts of aggravated attempted murder, one count of robbery, one count of failure to stop, and one count of theft. The trial court sentenced Appellant to an aggregate of 225 years of incarceration, with no less than thirty years to be served. The State later agreed that the sentence imposed was unlawful. The Supreme Judicial Court vacated the sentences, holding that the court imposed consecutive sentences without making the required findings and providing the required explanation for each conviction, in violation of Me. Rev. Stat. 17-A, 1608(1). View "State v. Murray-Burns" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for aggravated trafficking of scheduled drugs and unlawful possession of scheduled drugs, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not commit clear error when it allowed ta confidential informant (CI) to testify regarding the manner in which he had previously met with Defendant to obtain drugs; (2) any prosecutorial error during closing argument about the role of CIs in society did not affect Defendant's substantial rights; and (3) there was no error in the jury instructions given during the proceedings below. View "State v. Osborn" on Justia Law